Privacy Policy

Information about the personal data controller:

„Intercontinental Training Center“ Ltd., registered under the Commercial Law of the Republic of Bulgaria, with UIC: 203657843, with its registered office and address of management in Country: BULGARIA, Province: Sofia (capital), Municipality: Sofia City, City: Sofia, ZIP Code 1000, Triaditsa District, 55 Alexander Stamboliyski Blvd.

We process your personal data on the following grounds:

• The contract concluded between us and you for the purpose of fulfilling our obligations under it;
• Your explicit consent—the purpose is specified for each specific case;
• When required by law.

In the following paragraphs, you will find detailed information regarding the processing of your personal data, depending on the legal basis on which we process it.

FOR THE PERFORMANCE OF A CONTRACT OR IN THE CONTEXT OF PRE-CONTRACTUAL RELATIONSHIPS

We process your personal data to fulfill our contractual and pre-contractual obligations and to exercise our rights under the contracts we have entered into with you.

Purposes of processing:

• to verify your identity;
• processing and fulfilling your request and performing a concluded contract;
• drafting a proposal for entering into a contract;
• preparing and sending an invoice for the services you use from us;
• to provide you with the comprehensive service you need, as well as to collect the amounts due for the services you have used;
• retaining correspondence related to orders placed, processing requests, reporting issues, etc.
• notifications regarding everything related to the services you use with us;
• to identify and/or prevent unlawful actions or actions that violate our terms and conditions for the relevant services;

Data we process on this basis:

Based on the contract concluded between us and you, we process information regarding the nature and content of the contractual relationship, as well as any other information related to the contractual relationship, including:

• personal contact information—email address, phone number, and other details
• identification information – first and last name, shipping address, email address;
• other feedback we receive from you;
• information about your activities on our website.
• The processing of the personal data listed above is necessary for us to enter into and fulfill the contract with you. Without the personal data listed above, we would not be able to fulfill our obligations under the contract.

Do we share personal data with third parties?

We share your personal data with third parties, with our primary goal being to provide you with high-quality, fast, and comprehensive service. We do not share your personal data with third parties until we have verified that all technical and organizational measures have been taken to protect that data, and we strive to maintain strict oversight to ensure this objective is met. In such cases, we remain responsible for the confidentiality and security of your data.

We disclose personal data to the following categories of recipients (data controllers):

• postal operators and courier companies;
• persons who, under contract, maintain the equipment, software, and hardware used for the processing of personal data and necessary for the company’s operations
• individuals who provide consulting services in various fields

When do we delete the data collected on this basis?

We delete the data collected on this basis 5 years after the termination of the contractual relationship, regardless of whether the termination was due to the expiration of the contract, termination, or any other reason. 

TO FULFILL REGULATORY OBLIGATIONS

The law may require us to process your personal data. In such cases, we are obligated to carry out the processing, such as:

• obligations under the Anti-Money Laundering Act;
• fulfillment of obligations related to distance sales and off-premises sales, as provided for in the Consumer Protection Act;
• providing information to the Consumer Protection Commission or to third parties as provided for in the Consumer Protection Act;
• providing information to the Personal Data Protection Commission in connection with obligations set forth in the personal data protection regulations;
• obligations set forth in the Accounting Act, the Tax and Social Security Procedural Code, and other relevant regulations, regarding the maintenance of proper accounting records;
• providing information to the court and third parties in the context of court proceedings, in accordance with the requirements of the laws and regulations applicable to such proceedings;

When do we delete personal data collected on this basis?

We delete data collected in accordance with a legal obligation once the obligation to collect and store such data has been fulfilled or has ceased to apply. For example:

• in accordance with the Accounting Act regarding the storage and processing of accounting data (11 years),
• obligations to provide information to the court, competent government authorities, and other grounds provided for in current legislation (5 years).
• Disclosure of Data to Third Parties
• When we are required by law to do so, we may disclose your personal data to the competent government authority, natural person, or legal entity.

AFTER YOU HAVE GIVEN YOUR CONSENT

We process your personal data on this basis only after receiving your explicit, unambiguous, and voluntary consent. We will not impose any adverse consequences on you if you refuse to consent to the processing of your personal data.

Consent is a separate legal basis for processing your personal data, and the purpose of the processing is specified therein and does not overlap with the purposes listed in this policy. If you provide us with the relevant consent, and until you withdraw it or we terminate any contractual relationship with you, we will prepare product/service offers tailored to you by conducting detailed analyses of your basic personal data;

Detailed analysis is a method of conducting analysis that enables the processing of large volumes of data using statistical models, algorithms, and other tools that involve the use of personal data, as well as processes for pseudonymizing and anonymizing such data, in order to extract information about trends and various statistical indicators.

Data we process on this basis:

On this basis, we process only the data for which you have given us your explicit consent. The specific data is determined on a case-by-case basis. Typically, the data includes:

• Email
• Names
• Address
• Phone number
• IP Address
• Others

Disclosure of Data to Third Parties

On this basis, we may share your data with marketing agencies, Facebook, Google, or other similar entities.

Withdrawal of Consent

Consent that has been given may be withdrawn at any time. Withdrawal of consent does not affect the fulfillment of contractual obligations. If you withdraw your consent to the processing of personal data for any or all of the purposes described above, we will not use your personal data and information for the purposes specified above. Withdrawal of consent does not affect the lawfulness of processing based on consent given prior to its withdrawal.

To withdraw your consent, simply use our website or contact us.

When do we delete the data collected on this basis?

We delete the data collected on this basis upon your request or 6 months after it was initially collected.

PROCESSING OF ANONYMIZED DATA

We process your data for statistical purposes, which means for analyses in which the results are only summary in nature and the data is therefore anonymous. It is impossible to identify a specific individual from this information.

Your data may also be anonymized. Anonymization is an alternative to data deletion. During anonymization, all personally identifiable elements (elements that allow you to be identified) are irreversibly removed. There is no legal obligation to delete anonymized data, as it does not constitute personal data.

Why and How We Use Automated Algorithms

To process your personal data, we use partially automated algorithms and methods in order to continuously improve our products and services and to tailor them to your needs in the best possible way. This process is called profiling.

How We Protect Your Personal Data

To ensure adequate protection of the company’s data and that of its customers, we implement all necessary organizational and technical measures provided for in the Personal Data Protection Act.

The company has established rules to prevent abuse and security breaches.

To ensure maximum security when processing, transferring, and storing your data, we may use additional security measures such as encryption, pseudonymization, and others.

Personal data we have received from third parties

We may receive personal data about you from our other users.

Consumer Rights

Every user of the website is entitled to all rights regarding the protection of personal data under Bulgarian law and European Union law.

Users can exercise their rights by using the contact form or by sending a message to our email address.

Every User has the right to:

• Right to be informed (regarding the processing of his personal data by the controller);
• Access to your own personal data;
• Correction (if the data is inaccurate);
• Deletion of personal data (the „right to be forgotten“);
• Restriction of processing by the controller or processor;
• Portability of personal data between individual controllers;
• Objection to the processing of his personal data;
• The data subject also has the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning the data subject or similarly significantly affects him or her;
• The right to seek legal or administrative remedies in the event that the data subject’s rights have been violated.
• The user may request deletion if one of the following conditions applies:
• The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
• The user withdraws the consent on which the data processing is based, and there is no other legal basis for the processing;
• The data subject objects to the processing, and there are no legitimate grounds for the processing that take precedence;
• The personal data was processed unlawfully;
• Personal data must be erased in order to comply with a legal obligation under Union law or the law of a Member State to which the controller is subject;
• The personal data was collected in connection with the provision of information society services to children, and consent was given by the person with parental responsibility for the child.

The user has the right to restrict the controller’s processing of their personal data when:

• Challenge the accuracy of the personal data. In this case, the restriction on processing shall apply for a period that allows the controller to verify the accuracy of the personal data;
• The processing is unlawful, but the User does not wish to have the personal data erased; instead, the User requests that its use be restricted;
• The controller no longer needs the personal data for the purposes of processing, but the user requires it to establish, exercise, or defend legal claims;
• Objects to the processing pending verification of whether the controller’s legitimate grounds take precedence over the User’s interests.
• Right to data portability.
• The data subject has the right to receive the personal data concerning him or her that he or she has provided to a controller, in a structured, commonly used, and machine-readable format, and has the right to transmit those data to another controller without hindrance from the controller to whom the personal data were provided, when the processing is based on consent or a contractual obligation and the processing is carried out by automated means.
• When exercising their right to data portability, the data subject has the right to receive and have their personal data transferred directly from one controller to another, where technically feasible.

Right to object.

Users have the right to object to the controller regarding the processing of their personal data. The data controller is required to cease processing unless it can demonstrate that there are compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims. In the event of an objection to the processing of personal data for direct marketing purposes, the processing must be discontinued immediately.

Complaint to the supervisory authority

Every User has the right to file a complaint regarding the unlawful processing of their personal data with the Personal Data Protection Commission or with the competent court.

Maintenance of a Register

We maintain a record of the processing activities for which we are responsible. This record contains all of the information listed below:

• the administrator's name and contact information
• the purposes of the processing;
• a description of the categories of data subjects and the categories of personal data;
• the categories of recipients to whom the personal data has been or will be disclosed,
• including recipients in third countries or international organizations;
• whenever possible, the timeframes specified for the erasure of the various categories of data;
• where possible, a general description of the technical and organizational security measures,

This Privacy Policy was adopted and approved on February 2, 2026, by „Intercontinental Training Center“ Ltd.